The IRS and the DOL granted temporary relief to plan sponsors following this year's super-storm, but what impact will it have on fiduciary responsibilities in 2013?
In prior entries, we have discussed a variety of issues related to the fee disclosure responsibilities of broker/dealers and financial advisors. This month, well address the impact of the 408(b)(2) disclosure regulations on third party administrators.
Although the regulations have been withdrawn, it's likely that the re-issued regulations will be substantially similar. As such, it's important to have a good understanding of the DOLs approach in order to be fully prepared when the new rules are in place.
An important aspect of the regulations that is often overlooked is the requirement that service providers must justify compensation by describing the services they provide.
The 408(b)(2) requirements are now effective as of April 1, 2012 (instead of July 16, 2011). The extension not only gives all of us in the industry extra time to prepare, but it also gives us a chance to stop, take a deep breath, and assess what our respective disclosure...
As most of you already know, 2010 was a banner year for the Department of Labor. In quick succession, the DOL issued three major pieces of guidance related to retirement plans.